In Washington v. African Methodist Episcopal Church, Inc., Case No. 11-CV-6087-CJS, 2011 WL 4352404 (W.D.N.Y. Sept. 16, 2011), the court ruled that the Free Exercise Clause of the First Amendment precluded subject matter jurisdiction over a pastor’s and his wife’s claim against their former church and bishop based on breach of contract, intentional infliction of emotional distress, prima facie tort, and loss of consortium. The pastor argued that the bishop and conference terminated him in malice without reason or bona fide relation to his job performance. The plaintiffs argued that the court could assert jurisdiction over their New York common law claims, because the New York state courts had done so based on their authority under the New York Religious Corporations Law. But the court found that “[i]t became apparent at oral argument that both sides were relying on the [AME Church] Book of Discipline to determine whether the transfer was proper. To adjudicate this question, the court would necessarily have to interpret the AME Church’s spiritual guidance, thus entangling itself in Defendant’s Free Exercise rights under the First Amendment.”